Sizing the investment: equipment lists, supplier quotations, and the oversizing trap

In short: The amount of an investment is not decided, it is demonstrated. The template in Annex V to Decree No. 26-154 calls, at III.3, for a “detailed list of valued equipment” and, at V.1, for an initial investment comprising equipment, buildings, engineering and working capital. Yet the list of goods and services eligible for benefits (Annex II to Decree No. 22-299) has only two columns — designation and quantity, no value at all — and is stamped page by page by the one-stop desk. And the bank file requires a proforma invoice less than three months old for each line. Three readings of the same table. This article shows how to hold them together, which lines Decree No. 22-300 excludes from the benefits, and what an oversized investment costs.

Keywords in this article

valued equipment list investment plan proforma invoice working capital engineering / assembly non-eligible goods used equipment oversizing amending list Annex V, part III.3 Decree 22-300

1. Why does the equipment list legally bind the project sponsor?

In the files we take over, the equipment list usually arrives last, treated as a technical annex to be filled in for good measure. That misreads the document. It is one of the few pieces of an investment file that carries an administrative stamp, a signed undertaking, and a measurable cost if the figures later diverge.

Law No. 22-18 of 24 July 2022 on investment provides in Article 25 that the registration certificate issued by the competent one-stop desk comes with the list of goods and services eligible for benefits. Executive Decree No. 22-299 of 8 September 2022 sets out the mechanics: the list is filed with the registration application, before the investment begins, using the template in its Annex II (Article 3).

Three provisions change the nature of the exercise:

  • Article 11 of Decree 22-299 — the one-stop desk stamps every page of the list. The same provision allows a subsequent audit: ineligible goods are removed from the list, and duties are recovered if the benefits have already been used.
  • Article 13 of the same decree — the VAT exemption authorisation is issued within seventy-two (72) hours, on presentation of a proforma invoice for the goods to be acquired. Benefits may be used only after entry in the commercial register and allocation of the tax identification number.
  • Article 14 of Law 22-18 — goods and services that have received benefits may be transferred or assigned only with the authorisation of the Agency.

What goes on that list therefore determines what enters duty-free, what may later be resold, and what may be reassessed years afterwards. Sizing an investment is not filling in a table: it is fixing a perimeter that will have to be delivered.

And the list serves twice over. The techno-economic study template, at Annex (V) to Executive Decree No. 26-154, devotes its part III.3 "Equipment and installations" to it: a "detailed list of valued equipment", "technical characteristics", "source of the equipment and prospective suppliers". The same inventory therefore feeds both the study that argues for the project and the list that unlocks the benefits — with, as we shall see, opposite requirements on prices.

2. Why do the AAPI and the bank not ask for the same list?

Because they are not reading the same thing. The Agency defines a perimeter: which goods enter directly into the delivery of the investment. The bank prices a financing need: how much, by when, and on what evidence of price.

The sharpest detail turns on a single word. The Annex (V) template asks for a list of "valued" equipment — priced, that is. The template for the list of eligible goods, by contrast, has no value column at all. The same inventory must therefore be priced in the study and stripped of its prices in the stamped list. That is precisely where the two documents fall out of step.

The contrast is written into the forms themselves. The Annex II template of Decree 22-299 has only two list columns — "Designation" and "Quantity" — alongside the identification of the investor and a sworn declaration undertaking how the goods will be used. No value, no origin, no tariff heading. Conversely, the investment loan file published by the BNA requires, in support of each line of the investment structure, a "recent proforma invoice and/or equipment purchase contract (less than three (03) months old)".

ItemAAPI list (Annex II, Decree 22-299)Bank file (documents published by the BNA)
Designation of the assetYes, a column of the formYes, by investment line
QuantityYes, a column of the formImplied by the supporting document
PriceNot provided for in the templateProforma invoice or purchase contract under three months old
Origin, tariff headingNot provided for in the templateNot required by the published list
Civil engineering worksOutside the scope of the goods listQuantified and estimated works schedule, where needed
Contribution in kindSeparate list, Annex V (Article 12)Valuation by an approved expert
TimetableOutside the scope of the listPhysical delivery schedule for the project
FormalitiesOne-stop desk stamp on every page (Article 11)Dated and signed documents

Based on our engagements, this gap generates more back-and-forth than anything else: an AAPI list that is acceptable but silent on prices, and a priced bank forecast whose quantities no longer match the stamped list. Both documents should come out of a single working table held by the project sponsor, rather than being rebuilt twice. This is a field observation, not a rule of law.

The forecast built on that table is the one described in our article on the five-year forecast income statement: depreciation flows directly from the investment structure fixed here.

3. How long does a supplier quotation stay valid in a file?

None of the texts read for this article — Law 22-18, Executive Decrees 22-299, 22-300 and 26-154 — sets a validity period for a supplier quotation. The word "quotation" does not even appear in the Annex (V) template, which asks only for the "source of the equipment and prospective suppliers" (III.3). The only published duration we found is a banking one: the BNA asks for a proforma invoice or purchase contract less than three months old.

That is enough to frame the assembly timetable, because four clocks run at once, at very different speeds.

ClockDurationOrigin
Expected freshness of a proforma invoiceLess than three monthsDocuments published by the BNA
VAT exemption authorisation72 hoursArticle 13 of Decree 22-299
Deadline to deliver the investmentThree years; five years under the zones regime and the structuring investments regimeArticle 32 of Law 22-18
Possible extension of that deadlineTwelve months, renewable onceArticle 32 of Law 22-18

Article 32 specifies that the delivery deadline runs from registration with the Agency or, where one is required, from the building permit. The order in which quotations are gathered is therefore not neutral: a quotation obtained too early will have expired for the bank, while one obtained too late postpones registration and, with it, the start of the deadline.

In the practice we observe, three difficulties recur on imported equipment:

  • the quotation denominated in foreign currency, where the exchange rate used in the forecast is written down nowhere — two readers then derive two different investment costs from the same document;
  • the incoterm nobody read: an ex-works price is not a delivered-on-site cost, and the difference rarely appears in the investment table;
  • the quotation that expires while the file is being examined, forcing a fresh request to the supplier and sometimes a revision of the financed amount.

These are observations from our engagements, not enforceable rules.

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4. Which investment lines are most often forgotten?

The question is not rhetorical: an understated investment is as dangerous as an inflated one, because the difference will have to be financed without any benefit and outside the loan envelope.

The template answers first through its vocabulary. Its part V "Investment plan" breaks the initial investment down into four lines only — "equipment", "buildings", "engineering / assembly", "working capital" — then separates "operating costs" and the "financing plan" (own-funds contributions, bank loans, partnerships). The text never in fact uses the phrase "cost of the investment": Article 6 of Decree No. 23-487, as rewritten by Article 2 of Decree No. 26-154 of 14 April 2026, says "forecast cost of the project" and requires a study "duly prepared by a qualified professional" in line with the template; the scoring grid in Annex (I) uses the criterion "amount of the investment"; and the specifications in Annex (IV) say, at Article 17, "overall cost of the project". Four expressions for one object.

Remember the two phrases that save a file: "engineering / assembly" and "working capital". The template names them both, and they are the two we most often see missing.

The table below sets the lines of an investment structure against their regulatory status. Only the last column comes from our practice and carries no regulatory force.

LineRegulatory statusUsual supporting documentFrequent omission (field observation)
Land and external site worksOutside the goods listConcession deed or decision, site works quotationFencing, roadways, manoeuvring area
Civil engineering and buildings"Buildings", template V.1Quantified and estimated scheduleSpecial foundations for heavy machinery
Production equipment"Detailed list of valued equipment", template III.3 — second-hand excluded from the benefits (Art. 6, Decree 22-300)Proforma invoice or purchase contractRarely omitted — more often oversized
Utilities and connections"Consumption and technical requirements", template III.4Utility operators' quotationsTransformer station, borehole, drainage
Transport, installation, commissioning"Engineering / assembly", template V.1Supplier or installer quotationVery often absent, though the template names it
Operator training on the equipmentNot named by Decree 22-300; general rules onlySupplier offerAbsent, although it conditions start-up
Spare parts and initial toolingExcluded from the benefits if booked as inventory (Art. 5 and Annex III, Decree 22-300)Supplier quotationAbsent, then funded from cash
Vehicles and handling equipmentRoad transport for own account excluded, save for plant used by brickworks, cement works, quarries and construction (Annex III, Decree 22-300)Proforma invoiceUndersized
Office furniture and equipmentExcluded where not directly used in production, save for IT equipment (Annex III, Decree 22-300)Proforma invoicePriced as though it carried benefits
Software and systemsNot named by Decree 22-300; general rules onlyVendor quotationAnnual licences confused with investment
Start-up working capital"Working capital", expressly named at template V.1 — but outside the goods listForecast cash-flow statementThe costliest omission of all

The last line deserves one of its own, and its status needs stating precisely. It appears on no goods list — so it unlocks no benefit, and no quotation supports it. But the Annex (V) template expressly names it among the four components of the initial investment. Omitting it is therefore not merely imprudent: it makes the study incomplete against its own template. It is priced in the forecast cash-flow statement, and its effect is read on the break-even point of the first year.

Two lines of the table read "general rules only", and it is worth saying exactly what that means. Training and software are named nowhere — neither in the articles of Decree 22-300 nor in its Annex III. That leaves only the general framework: Law No. 22-18 covers, at Article 4, "the acquisition of assets, tangible or intangible, entering directly into activities producing goods and services", and at Article 27 the "VAT exemption for goods and services imported or acquired locally, entering directly into the delivery of the investment"; while Article 5 of Decree 22-300 excludes goods falling under classes of the financial accounting system other than fixed assets. Capitalised software is therefore caught neither by Annex III nor by the exclusion of non-fixed assets — but no text read says it is eligible either. The question is settled at the one-stop desk, list in hand. One more reason to ask it before filing rather than after.

The second-hand equipment trap. Article 6 of Executive Decree No. 22-300 of 8 September 2022 excludes from the benefits "used capital goods, including production lines and equipment". Buying second-hand to bring the investment amount down therefore forfeits the benefit on the heaviest line of the table. The text carves out an exception for refurbished goods imported as a contribution in kind when an activity is relocated from abroad. Conversely, Article 7 of the same decree provides that the structuring investments of Article 30 of the law "are not concerned by the exclusions" it lays down.

5. What is the risk of oversizing the investment?

Two things: time you do not have, and costs you had not budgeted for.

Time first. Article 32 of Law No. 22-18 sets a delivery deadline that may not exceed three years, raised to five years under the zones regime and the structuring investments regime, extendable by twelve months renewable once. A project sized for a capacity the market does not yet justify is a project that consumes that deadline in phases it never manages to close.

Then the consequences. Article 36 of the same law provides that, where legal obligations or the investor's undertakings are not met, benefits may be withdrawn in part or in whole, without prejudice to other penalties. And Article 11 of Decree 22-299 adds the subsequent audit of the list, with recovery of duties on ineligible goods whose benefits have been used.

Oversizing also carries an immediate price. Articles 22 and 23 of Executive Decree No. 22-299 establish a fee for processing investment files, scaled by project size around a threshold of two billion dinars. The registration certificate costs DZD 60,000 below the threshold and DZD 400,000 above it — and for foreign investments whatever the amount. The five other acts (amending the certificate, cancelling registration at the investor's request, amending the list of goods, a duplicate, and the report recording entry into operation) cost DZD 40,000 and DZD 100,000 respectively. Crossing the threshold for an amount the project does not justify is therefore paid for on filing, and multiplies the cost of every later act by almost seven. Article 24 exempts from payment those acts intended to correct an error or omission not attributable to the investor.

That leaves the argument most often used to justify an inflated amount: the score. The "amount of the investment" is indeed one of the eight criteria in the scoring grid of Annex (I), in the version substituted by Article 5 of Decree No. 26-154 — coefficient 6, for a maximum of 360 points out of a total of 1,500. But the scale itself matters more than the maximum, and it is heavily weighted towards the very top.

Amount of the investmentMarkScore (coefficient 6)Share of 1,500 points
DZD 0.1 to under 0.5 billion10604.0%
DZD 1 to under 2 billion201208.0%
DZD 2 to under 5 billion3018012.0%
DZD 100 billion and above6036024.0%

Four bands are enough to show the mechanism; the scale has ten, set out in our article on the grid. Read the first two rows together. A project of two hundred million dinars scores 60 points out of 1,500. Inflating it to one and a half billion lifts that to 120 — sixty points gained, four per cent of the total. But crossing two billion to reach the 180-point band tips the registration fee from DZD 60,000 to DZD 400,000, and every later act from DZD 40,000 to DZD 100,000. Oversizing is therefore paid in cash and rewarded in percentage points.

Add to that what the grid scores more heavily, and what an inflated amount will not deliver: employment carries coefficient 5 and up to 300 points, own-funds contributions coefficient 4 and up to 200 points — and an oversized investment mechanically lowers the own-funds share. The full detail is in our article on the economic land scoring grid.

Based on our engagements, oversizing almost always has the same origin, and it is not bad faith: an installed capacity set on the most favourable commercial scenario, followed by a "while we are at it" effect on ancillary equipment. The symptom is recognisable — a very low capacity utilisation rate over the first two years, holding up only through a very rapid ramp-up. A field observation, not a rule.

6. Can the goods list be corrected after registration?

Yes, and the text expressly provides for it. Article 18 of Executive Decree No. 22-299 allows the lists drawn up under its Articles 11 and 12 to be amended, using the template in its Annex VIII; the corrected lists take the form of amending lists (Annex IX). The same article specifies that partial commissioning does not prevent such amendments. The AAPI does publish the corresponding forms — application to amend the list of goods and services eligible for benefits, list of goods constituting contributions in kind, investment project progress report, and application for a report recording full or partial entry into operation.

The point to retain is that the procedure exists but is free neither in time nor in money. An amending list goes through the same steps as the original, stamp included, and "amendment of lists of goods and services" is named in the tariff of Article 23 of Decree No. 22-299: DZD 40,000 for a project below two billion dinars, DZD 100,000 above it and for foreign investments. Three successive revisions therefore cost DZD 120,000 in the first case and DZD 300,000 in the second — on top of the time.

In the practice we observe, a sponsor who revises the list three times during delivery loses more time than building a serious investment table at the outset would have cost, and reaches the end of the delivery deadline with less room to manoeuvre. That is an observation from our engagements, not a prohibition.

What we actually do on a file of this kind: start from real quotations before writing down the capacity, not the other way round; keep a single table from which the AAPI list, the bank investment structure and the forecast depreciation all flow; and date every quotation so that the bank's three-month window is still open at filing. The rest of the file — techno-economic study template, forecasts, profitability — is built on top. The price of the study depends directly on the quality of that raw material.

This article sets out a sizing method and example lines with illustrative values; it constitutes neither legal advice, nor investment advice, nor any guarantee of obtaining financing or a benefit. The texts cited must be checked in the version in force at the date of the file, and every decision must rest on the actual quotations and data of the project.

FAQ — Frequently asked questions

Sources and references

  • Law No. 22-18 of 24 July 2022 on investment — Article 4 (investment means, among other things, “the acquisition of assets, tangible or intangible, entering directly into activities producing goods and services”) ; Article 14 (transfer or assignment of goods and services that have received benefits, subject to authorisation from the Agency); Article 25 (the registration certificate is accompanied by the list of goods and services eligible for benefits); Article 32 (delivery deadline that may not exceed three years, raised to five years under the zones regime and the structuring investments regime, running from registration or from the building permit, extendable by twelve months renewable once); Article 36 (withdrawal of benefits in part or in whole where legal obligations or the investor's undertakings are not met); Article 27 (exemption from customs duties for imported goods entering directly into the delivery of the investment; VAT exemption for goods and services imported or acquired locally entering directly into the delivery of the investment); Articles 39 and 40 (transfer to the Agency of the portfolio previously within the remit of the National Investment Council; repeal of Law No. 16-09, save for its Article 37) — Official Journal of the Algerian Republic No. 50 of 28 July 2022 · Verified on 23/10/2026
  • Executive Decree No. 22-299 of 11 Safar 1444 corresponding to 8 September 2022 setting the procedures for registering investments, their assignment or transfer, and the amount of the file processing fee (JO p. 12) — Article 3 and Annex II (the list of goods and services is filed with the registration application, before the investment begins; the template has only the “Designation” and “Quantity” columns, with a sworn declaration undertaking how the goods will be used); Article 11 (one-stop desk stamp on every page, subsequent audit, removal of ineligible goods and recovery of duties); Article 12 and Annex V (new goods constituting contributions in kind); Article 13 (benefits usable only after entry in the commercial register and allocation of the tax identification number; VAT exemption authorisation issued within seventy-two (72) hours on presentation of a proforma invoice for the goods to be acquired); Article 18 and Annexes VIII and IX (amendment of the lists, amending lists, partial commissioning no obstacle); Articles 22, 23 and 24 (file processing fee, two tables at Article 23, p. 14: for projects below two billion dinars, DZD 60,000 for the investment registration certificate and DZD 40,000 for each of the five other acts — amendment of the certificate, cancellation of registration at the investor's request, amendment of lists of goods and services, duplicate of a list or certificate, and establishment of the report recording entry into operation; for projects equal to or above two billion dinars and for foreign investments, DZD 400,000 and DZD 100,000 for the same items; Article 24: exemption for “any act drawn up by the agency to correct an error or omission not attributable to the investor”). Amounts verified in force at 23/10/2026: no text published in the Official Journal between No. 60 of 18 September 2022 and No. 73 of 2026 amends Article 23, and none of the four finance acts for 2023, 2024, 2025 and 2026 refers to the registration of investments, the Agency, Law No. 22-18 or Decree No. 22-299 — Official Journal of the Algerian Republic No. 60 of 18 September 2022 · Verified on 23/10/2026
  • Executive Decree No. 22-300 of 11 Safar 1444 corresponding to 8 September 2022 setting the lists of activities, goods and services not eligible for benefits, and the minimum financing thresholds for the transfer guarantee (pp. 27 to 37; Article 1 : made under Articles 8, 25, 26 and 29 of Law No. 22-18) — Article 2 (definition of goods and services entering directly into the delivery of the investment: any movable or immovable, tangible or intangible asset, acquired or created, intended for lasting use, and any service linked to its acquisition or creation); Articles 3 and 4 (non-eligible activities, Annexes I and II; activities outside the actual-profit tax regime or not subject to the commercial register); Article 5 (excluded are all goods falling under classes of the financial accounting system other than fixed-asset accounts, save exception, together with the fixed-asset accounts listed in Annex III); Article 6 (exclusion of “used capital goods, including production lines and equipment”, with an exception for refurbished goods imported as a contribution in kind when an activity is relocated from abroad); Article 7 (the structuring investments of Article 30 of the law are not concerned by these exclusions); Annex III, p. 37 (non-eligible goods: road transport equipment for goods and persons for own account, save plant and goods-transport equipment of brickworks, cement works, quarries, construction and similar activities; office and communication equipment not directly used in production, save IT equipment; returnable packaging; general installations, fittings and various works, with exceptions for classified hotels and restaurants; social amenities; and class 3 inventories and work in progress) — Official Journal of the Algerian Republic No. 60 of 18 September 2022 · Verified on 23/10/2026
  • Executive Decree No. 26-154 of 26 Chaoual 1447 corresponding to 14 April 2026 amending and supplementing Executive Decree No. 23-487 of 28 December 2023 setting the conditions and procedures for concession convertible into sale of economic land intended for investment projects (pp. 12 to 26) — Article 2 (the new Article 6 of Decree 23-487 requires the application to be submitted through the investor digital platform and a techno-economic study “duly prepared by a qualified professional, in line with the template at Annex (V)”, together with evidence of the declared own-funds contributions; p. 13); Article 5 (replacement of Annexes (I) to (IV) and addition of Annex (V); p. 14); ANNEX (V) “THE TECHNO-ECONOMIC STUDY TEMPLATE” (p. 26, in full on that page) — I. General information on the project sponsor; II. General presentation of the project; III. Technical study, including III.2 “Production capacity” (planned annual volume; yield, utilisation rate) and III.3 “Equipment and installations” (“detailed list of valued equipment”; “technical characteristics”; “source of the equipment and prospective suppliers”) and III.4 “Consumption and technical requirements”; IV. Market study; V. “Investment plan” (V.1 initial investment: equipment, buildings, engineering / assembly, working capital; V.2 operating costs; V.3 financing plan: own-funds contributions, bank loans, partnerships); VI. Economic and financial forecasts (forecast income statement, cash-flow statement and balance sheet over 3 to 5 years; profitability: IRR, NPV, break-even point, margin rate); VII. Socio-economic impact; VIII. “Delivery schedule”; IX. Annexes. The words “quotation” and “cost of the investment” do not appear in Annex (V). ANNEX (I) scoring grid (p. 15, observations p. 16) — criterion “amount of the investment”, coefficient 6, reference mark 5 to 60; scale: below DZD 0.1 billion mark 5 (30 points), 0.1 to under 0.5 billion mark 10 (60), 0.5 to under 1 billion mark 15 (90), 1 to under 2 billion mark 20 (120), 2 to under 5 billion mark 30 (180), 5 to under 7 billion mark 35 (210), 7 to under 10 billion mark 40 (240), 10 to under 50 billion mark 50 (300), 50 to under 100 billion mark 55 (330), 100 billion and above mark 60 (360); other criteria: nature of the activity coefficient 7 (up to 420), employment coefficient 5 (up to 300), own-funds contributions coefficient 4 (up to 200), local content coefficient 2 (up to 60), job sustainability, extension of the investment and export diversification coefficient 1; “Maximum score: 1500” on the last line; the text sets neither a minimum score nor a tie-break rule. Terminology recorded: “forecast cost of the project” at Article 6, “amount of the investment” in the Annex (I) grid, and “overall cost of the project” at Article 17 of the specifications in Annex (IV) — Official Journal of the Algerian Republic No. 31 of 28 April 2026 · Verified on 23/10/2026
  • Investment loan file requirements (document published by the bank) — requirement for a “recent proforma invoice and/or equipment purchase contract (less than three (03) months old)” supporting each line of the investment structure, a “quantified and estimated works schedule” where needed, a valuation by an approved expert for any contribution in kind, a physical delivery schedule for the project, an investment financing plan, and forecast balance sheets over the term of the loan — Banque nationale d'Algérie (BNA) · Verified on 22/10/2026
  • Investor toolkit — forms published by the Agency: “List of goods and services eligible for benefits”, “List of goods constituting contributions in kind”, “Application to amend the list of goods and services eligible for benefits”, “Investment project progress report (22-18 scheme)”, “Application for a report recording full or partial entry into operation”. Caveat: the same page carries passages from the former regime — a five-billion-dinar threshold and the remit of the National Investment Council, and a reference to a 2008 interministerial order — which no text in force supports, and one sentence of which contradicts itself. The page is therefore cited only for the existence and titles of the published forms, never for substance — Algerian Agency for Investment Promotion (AAPI) · Verified on 23/10/2026
  • Executive Decree No. 23-487 of 28 December 2023 setting the conditions and procedures for concession convertible into sale of economic land — Annex (I) “Scoring grid” in its original version (pp. 10 to 12): “Total score: 1000” on the last line, across seven criteria. That annex was replaced by Article 5 of Executive Decree No. 26-154 of 14 April 2026, whose grid totals 1500 points: the two figures in circulation therefore correspond to two successive versions of the same text, not to a contradiction — Official Journal of the Algerian Republic No. 85 of 30 December 2023 · Verified on 23/10/2026
BENSAID Farouk ProfitPilot

BENSAID Farouk

Financial & Economic Research Consultant — ProfitPilot NextGen Consulting

Certified sole trader and expert in financial studies, risk analysis and market research for SMEs, startups and investors in Algeria. View full profile